https://www.taxtmi.com/caselaws?id=457258 ITAT Kolkata held that CIT's revision u/s 263 was unjustified as AO had made adequate enquiries regarding applicability of section 2(22)(e) to inter-group company loans. AO had called for and received details of unsecured loans from group companies and shareholding patterns during assessment proceedings u/s 153A/143(3). After examining relevant documentary evidence, AO consciously decided section 2(22)(e) was not applicable to the loan amounts. ITAT found no error in AO's assessment order as proper verification was conducted before concluding non-applicability of deemed dividend provisions. Assessee's appeal was allowed. en-us Wed, 29 May 2019 00:00:00 +0530 Thu, 12 Sep 2024 21:27:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457258 ITAT Kolkata held that CIT's revision u/s 263 was unjustified as AO had made adequate enquiries regarding applicability of section 2(22)(e) to inter-group company loans. AO had called for and received details of unsecured loans from group companies and shareholding patterns during assessment proceedings u/s 153A/143(3). After examining relevant documentary evidence, AO consciously decided section 2(22)(e) was not applicable to the loan amounts. ITAT found no error in AO's assessment order as proper verification was conducted before concluding non-applicability of deemed dividend provisions. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 29 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457258